Amicus Curiae Brief — Danco Laboratories, LLC, Applicant v. Louisiana, et al.

Supreme Court briefMay 6, 2026

Ask Donna

What actually matters in this document.

Text

No. 25A1207, 25A1208

IN THE

DANCO LABORATORIES, LLC, et al.,

Applicants,

v.

THE STATE OF LOUISIANA, et al.,

Respondents.

GENBIOPRO, LLC, et al.,

Applicant,

v.

THE STATE OF LOUISIANA, et al.,

Respondents.

_____________

BRIEF OF AMICI CURIAE 360 REPRODUCTIVE

HEALTH RESEARCHERS IN SUPPORT OF APPLICATIONS BY DANCO AND GENBIOPRO TO

STAY OR VACATE THE FIFTH CIRCUIT'S STAY

PENDING APPEAL

Alexander N. Ely

Counsel of Record

Doménica Merino

Quynhanh N. Tran

O’MELVENY & MYERS LLP

1625 Eye Street, N.W.

Washington, DC 20006

(202) 383-5400

aely@omm.com

Leah Godesky

O’MELVENY & MYERS LLP

1999 Avenue of the Stars

Los Angeles, CA 90067

(310) 553-6700

Amanda Barrow

Cathren Cohen

Sofia Espinoza

Melissa Goodman

Diana Kasdan

CENTER ON REPRODUCTIVE

HEALTH, LAW, AND POLICY

UCLA SCHOOL OF LAW

1060 Veteran Avenue

Los Angeles, CA 90095

(310) 267-4382

i

TABLE OF CONTENTS

Page

INTEREST OF AMICI CURIAE ............................... 1

SUMMARY OF ARGUMENT.................................... 1

ARGUMENT .............................................................. 4

I. FDA’s 2021 Decision to Remove the In-Person

Dispensing Requirement from the REMS,

Formalized in 2023, Was Supported by More

Than Ample Scientific Evidence. .................... 4

A. The April 2021 Decision to Not Enforce

the In-Person Dispensing Requirement

Was Supported by Substantial Scientific

Evidence. ................................................... 6

B. FDA Relied on and Discussed Additional

Evidence in Its December 2021 Analysis

Supporting the Safety and Effectiveness

of Removing the In-Person Dispensing

Requirement. ............................................ 9

C. Additional Evidence Issued Before FDA’s

2023 Final Decision Supports the Safety

and Effectiveness of Removing the InPerson Dispensing Requirement............ 12

D. Plaintiffs Incorrectly Suggest That FDA

Ignored Studies Showing Remote

Dispensing Might Lead to More

Emergency-Room Follow-Up Visits. ...... 13

ii

TABLE OF CONTENTS

(continued)

Page

E. FDA Properly Relied on Adverse Event

Reporting to Conclude That Removing the

In-Person Dispensing Requirement

Would Not Compromise Patient Safety. 14

II. The Body of Scientific Evidence Published

Since 2023 Further Confirms the Safety and

Effectiveness of Medication Abortion Without

an In-Person Dispensing Requirement ........ 16

A. Additional Scientific Evidence Lends

Further Support for Removing the InPerson Dispensing Requirement............ 16

B. Plaintiffs Have Not Identified Any Sound

Science Undercutting the Decision to

Remove the In-Person Dispensing

Requirement. .......................................... 20

CONCLUSION ......................................................... 26

iii

TABLE OF AUTHORITIES

Page(s)

Cases

All. for Hippocratic Med.,

2023 WL 2913725 (5th Cir. Apr. 12, 2023) .......... 13

Statutes

21 U.S.C. § 355-1(g)(4)(A) .......................................... 4

21 U.S.C. § 355 (d)...................................................... 4

21 U.S.C. § 355-1(f)(2) ................................................ 5

Other Authorities

Aiken et al., Effectiveness, safety and

acceptability of no-test medical abortion

(termination of pregnancy) provided via

telemedicine: a national cohort study, 128

BJOG 1464 (2021) .................................................. 8

Anger et al., Clinical and service delivery

implications of omitting ultrasound before

medication abortion provided via direct-topatient telemedicine and mail in the US, 104

CONTRACEPTION 659 (2021) .................................. 10

Arey, Self-diagnosing the end of pregnancy

after medication abortion, 26 CULT. HEALTH

SEX. 405 (2024) ..................................................... 22

Boos et al., Trends in the Use of Mifepristone

for Medical Management of Early Pregnancy

Loss From 2016 to 2020, 330 JAMA 766

(2023) .................................................................... 23

iv

TABLE OF AUTHORITIES

(continued)

Page(s)

Center for Drug Evaluation and Research,

Application Numbers: 020687 and 91178

Rationale Review (Dec. 16, 2021) .............. 9, 11, 15

Chen et al., Mifepristone with Buccal

Misoprostol for Medical Abortion, a

Systematic Review, 126 OBSTET. &

GYNECOL. 12 (2015) ................................................ 7

Chong et al., Expansion of direct-to-patient

telemedicine abortion service in the United

States and experience during the COVID-19

pandemic, 104 CONTRACEPTION 43 (2021) ............. 7

Cleeve et al., The use of telemedicine services

for medical abortion, 4 COCHRANE DATABASE

SYSTEMIC REVS. (2025) ......................................... 17

Executive Order, Restoring Gold Standard

Science (May 23, 2025),

https://www.whitehouse.gov/presidentialactions/2025/05/restoring-gold-standardscience ................................................................... 21

FAERS Public Dashboard – FAQ, FDA

https://fis.fda.gov/extensions/FPDFAQ/FPD-FAQ.html ............................................. 15

Frederiksen et al., The limitations of using

Medicaid administrative data in abortion

research. 142 CONTRACEPTION 110704 (2025) ..... 23

v

TABLE OF AUTHORITIES

(continued)

Page(s)

Grossman et al., Mail-order pharmacy

dispensing of mifepristone for medication

abortion after in-person clinical assessment,

107 CONTRACEPTION 36 (2022) ............................. 11

Grossman et al., Mail-Order Pharmacy

Dispensing of Mifepristone for Medication

Abortion After In-Person Screening, 184

JAMA INTERN. MED. 873 (2024)........................... 18

Hall et al., Fact Sheet: Data Reveals the FDA’s

Removal of In-Person Dispensing

Requirement Increased the Dangers of the

Abortion Pill, ETHICS & PUB. POL’Y CTR.

(2026),

https://media.eppc.org/2026/03/FACTSHEET-Data-on-FDA-Removal-of-Inperson-dispensing-requirement-2.pdf.................. 24

Hall et al., The Abortion Pill Harms Women:

In-surance Data Reveals One in Ten

Patients Experiences a Seri-ous Adverse

Event, ETHICS & PUB. POL’Y CTR. (2025),

2, 5, https://eppc.org/publication/insurancedata-reveals-one-in-ten- patientsexperiences-a-serious-adverse-event ..21, 22, 23, 24

Hunter et al., Test or No-Test: Comparison of

Medication Abortion Outcomes and Adverse

Events When Forgoing Ultrasound,

Laboratory Testing, and Physical

Examination, 47 J. OBSTET. & GY CAN.

(2024) .................................................................... 18

vi

TABLE OF AUTHORITIES

(continued)

Page(s)

Hyland et al., A direct-to-patient telemedicine

abortion service in Australia: Retrospective

analysis of the first 18 months, 58 AUSTL. &

N.Z. J. OBSTET. & GYNECOL. 335 (2018) ............... 11

Janet Woodcock, Acting Commissioner of Food

& Drugs, to Mauren Phipps, Chief

Executive Official, Am. Coll. Of

Obstetricians & Gynecologists, and William

Grobman, President, Soc’y for MaternalFetal Med. (Apr. 12, 2021) ......................... 6, 7, 8, 9

Kaplan et al., Review of Evidence Supporting

2022 US Food and Drug Administration

Drug Approvals, 6 JAMA NETWORK OPEN

e2327650 (2023) ...................................................... 5

Kerestes et al., Provision of medication

abortion in Hawai’i during COVID-19:

Practical experience with multiple care

delivery models, 104 CONTRACEPTION 49

(2021) ...................................................................... 7

Kessler, Digging Into the math of a study

attacking the safety of the abortion pill,

WASH. POST (May 12, 2025),

https://www.washingtonpost.com/politics/20

25/05/12/abortion-pill-medication-abortionstudy-mifepristone................................................ 20

vii

TABLE OF AUTHORITIES

(continued)

Page(s)

Koenig et al., Effectiveness and safety of

medication abortion with vs without

screening ultrasonography or pelvic

examination, 233 AM. J. OBSTETRICS &

GYNECOLOGY 453 (2025) ....................................... 18

Koenig et al., Mailing abortion pills does not

delay care: A cohort study comparing mailed

to in-person dispensing of abortion

medications in the United States, 121

CONTRACEPTION 109962 (2023) ........................... 19

Koenig et al., Patient Acceptability of

Telehealth Medication Abortion Care in the

United States, 2021‒2022: A Cohort Study,

114 AM. J. PUB. HEALTH 241 (Feb. 2024) ............. 19

Koenig et al., The Role of Telehealth in

Promoting Equitable Abortion Access in the

United States: Spatial Analysis, 9 JMIR

PUB. HEALTH AND SURVEILLANCE e45671

(2023) .................................................................... 19

Koenig et al., Virtual Clinic Telehealth

Abortion Services in the United States One

Year After Dobbs: Landscape Review, 26 J.

MED INTERNET RES. e50749 (2024) ...................... 25

Landman, A Convenient Piece of Junk Science,

ATLANTIC, (May 24, 2025),

https://www.theatlantic.com/health/archive/

2025/05/mifepristone-abortion-rfkfda/682939............................................................. 20

viii

TABLE OF AUTHORITIES

(continued)

Page(s)

Nobles et al., Abortion Restrictions Threaten

Miscarriage Management In The United

States, 43 HEALTH AFFAIRS (MILLWOOD)

1219 (2024) ........................................................... 23

Patrizia A. Cavazzoni, M.D., Director Center

for Drug Evaluation and Research to Donna

J. Harrison, M.D., Executive Director Am.

Ass’n of Pro-Life Obstetricians &

Gynecologists and Quentin L. Van Meter,

President, Am. Coll. of Pediatricians

denying in part and granting in part 2019

Citizen Petition (Dec. 16, 2021) ............................. 9

Ralph et al., Comparison of No-Test Telehealth

and In-Person Medication Abortion, 322

JAMA 898 (2024) .................................................. 17

Raymond et al., Evaluation of a “smart”

screening tool for asynchronous assessment

of medication abortion eligibility: A pilot

study, 131 CONTRACEPTION 110340 (2024) .......... 18

Raymond et al., First-trimester medical

abortion with mifepristone 200 mg and

misoprostol: A systematic review, 87

CONTRACEPTION 26 (2013) .................................... 22

Raymond et al., TelAbortion: evaluation of a

direct to patient telemedicine abortion

service in the United States, 100

CONTRACEPTION 173 (2019) .................................. 10

ix

TABLE OF AUTHORITIES

(continued)

Page(s)

Reynolds-Wright et al., Telemedicine medical

abortion at home under 12 weeks’ gestation:

a prospective observational cohort study

during the COVID-19 pandemic, 47 BMJ

SEX. REPROD. HEALTH 246 (2021) .......................... 9

Schreiber et al., Mifepristone Pretreatment for

the Medical Management of Early

Pregnancy Loss, 378 N. ENGL. J. MED. 2161

(2018) .................................................................... 23

Schummers et al., Abortion Safety and Use

with Normally Prescribed Mifepristone in

Canada, 386 N. ENG. J. MED. 57 (2022) ............... 13

Smith, The Safety and Efficacy of a “No

Touch” Abortion Program Implemented in

the Greater Toronto Area During the

COVID-19 Pandemic, 46 J. OBSTET. & GYN.

CAN. 102429 (2024)............................................... 18

Society of Family Planning, #WeCount Report

April 2022 through June 2025 (Dec. 9, 2025)

https://societyfp.org/wecount-report-10-june2025-data,

https://doi.org/10.46621/750591yxmcwh.............. 25

Srinivasulu et al., Telehealth Medication

Abortion in Primary Care: A Comparison to

Usual in-Clinic Care, 37 J. AM. BOARD FAM.

MED. 295 (2024) .................................................... 18

x

TABLE OF AUTHORITIES

(continued)

Page(s)

Tarleton et al., Society of Family Planning

Clinical Recommendation: Medication

management for early pregnancy loss, 144

CONTRACEPTION 110805 (2025) ............................ 23

U.S. FOOD AND DRUG ADMINISTRATION, What is

a Serious Adverse Event? (May 18, 2023),

https://www.fda.gov/safety/reportingserious-problems-fda/what-serious-adverseevent ................................................................ 13, 22

Upadhyay et al., Abortion-related emergency

department visits in the United States: An

analysis of a national emergency department

sample, 16 BMC MED. 88 (2018) .......................... 14

Upadhyay et al., Effectiveness and safety of

telehealth medication abortion in the USA.

30 NATURE MED. 1191 (2024) ............................... 17

Upadhyay et al., Incidence of Emergency

Department Visits and Complications After

Abortion, 125 OBSTET. & GYNECOL. 175

(2015) .................................................................... 14

Upadhyay et al., Outcomes and Safety of

History-Based Screening for Medication

Abortion: A Retrospective Multicenter Cohort

Study, 182 JAMA INTERNAL MED. 482 (2022) ....... 12

Upadhyay et al., Pricing of medication

abortion in the United States, 2021-2023, 56

PERSPECTIVES ON SEX. AND REPROD. HEALTH

282 (2024) ............................................................. 25

xi

TABLE OF AUTHORITIES

(continued)

Page(s)

Upadhyay et al., Safety and Efficacy of

Telehealth Medication Abortion in the US

During the COVID-19 Pandemic, 4 JAMA

NETWORK OPEN e2122320 (2021) ......................... 11

Regulations

21 C.F.R. § 314.80 .................................................... 15

INTEREST OF AMICI CURIAE1

Amici curiae2 are 360 leading reproductive health

researchers in the United States and worldwide.

Amici are trained and experienced in conducting or

evaluating clinical and social-science studies on reproductive health issues, including studies on the

safety and effectiveness of mifepristone. Amici share

a significant interest in evidence-based reproductive

health care and submit this brief to explain the ample

scientific evidence of mifepristone’s safety and effectiveness—including when prescribed via telehealth—

supporting the Food and Drug Administration’s 2021

decision, formalized in 2023, to lift the in-person dispensing requirement for mifepristone. A complete list

of amici can be found in the Appendix.

SUMMARY OF ARGUMENT

FDA’s decision to remove the in-person dispensing requirement from the mifepristone Risk Evaluation and Mitigation Strategy (“REMS”)—first announced in 2021 following a period of non-enforcement during the COVID-19 pandemic and then formalized in 2023—was supported by overwhelming

scientific evidence. Across multiple rounds of review,

FDA considered high-quality studies encompassing

more than 50,000 patient experiences, all of which

1 Pursuant to Supreme Court Rule 37.6, amici curiae state that

no counsel for any party authored this brief in whole or in part

and no entity or person, other than amici curiae, their members,

or their counsel, made any monetary contribution intended to

fund the preparation or submission of this brief.

2 A complete list of amici is provided in Appendix A. Amici’s affiliations are noted for informational purposes only, and amici

join this brief in their individual capacities only.

2

demonstrated that the in-person dispensing requirement is not necessary to ensure the safety and effectiveness of mifepristone for medication abortion.

These studies adhered to rigorous standards of reliability and validity, as demonstrated by their selection

for publication in reputable scientific journals, subject

to the rigorous academic peer-review process. FDA’s

review far exceeded the statutory threshold, which requires FDA to review only one adequate and well-controlled study to approve a drug and only an “adequate

rationale” to remove a REMS requirement. FDA also

properly determined that the in-person dispensing requirement for mifepristone ran counter to the statutory mandate that REMS elements not unduly burden

patient access, particularly for patients who have difficultly accessing health care, including those in rural

or medically underserved areas.

The scientific evidence published since 2023 has

only further confirmed the soundness of FDA’s decision. A rigorous 2025 Cochrane Review—widely recognized as the gold standard for evidence-based medicine—concluded that telehealth abortion using mifepristone is “generally safe, effective, and acceptable.”

And a 2024 study comparing telemedicine and in-person outcomes for concurrently recruited individuals

found no differences between the two groups in effectiveness or the number of serious adverse events.

Despite minor variations in results attributable

to study design and available data, the scientific research consistently demonstrates that telehealth provision of mifepristone is extremely safe and extremely

effective, with rates comparable to those observed in

studies assessing safety and effectiveness of

3

medication abortion care under the in-person dispensing requirement.

Plaintiffs have not identified any sound or reputable peer-reviewed scientific studies that would provide any basis for a court to second-guess FDA’s expert judgment in deciding to remove the in-person

mifepristone dispensing requirement. Plaintiffs rely

on a self-published report by the Ethics and Public

Policy Center (“EPPC”), but this report is riddled with

methodological flaws that render its conclusions unreliable. Indeed, EPPC has refused to disclose its underlying dataset, its methodology for identifying medication abortions, or the codes used to generate the

study cohort and analyze the data—preventing any

independent verification of its conclusions. EPPC

also inflated its serious adverse event figures by misclassifying outcomes such as follow-up treatment in

cases where the medication was not fully effective,

emergency room visits not requiring treatment or intervention, and normal post-abortion bleeding as “serious adverse events.” This methodologically flawed

study provides no basis for this Court to displace

FDA’s expert judgment to remove the in-person dispensing requirement.

The vast body of scientifically sound studies

leaves no doubt as to the safety and effectiveness of

mifepristone, including when provided by telehealth.

Consistent with this overwhelming evidence, this

Court should reverse the Fifth Circuit’s decision.

4

ARGUMENT

I.

FDA’s 2021 Decision to Remove the InPerson Dispensing Requirement from the

REMS, Formalized in 2023, Was Supported by More Than Ample Scientific

Evidence.

FDA’s decision to remove the REMS requirement

that mifepristone be dispensed only in person in clinics, medical offices, and hospitals (the “in-person dispensing requirement”) was the product of a measured,

multi-stage agency review grounded in rigorous scientific evidence. FDA first issued a nonenforcement

decision in April 2021, then lifted the in-person dispensing requirement in December 2021, and then finalized that decision in 2023. At each stage, FDA considered and cited rigorous scientific studies supporting the determination that the in-person dispensing

requirement was not necessary to ensure the safety

and effectiveness of mifepristone for medication abortion, and therefore did not meet the statutory standard needed for a REMS element to assure safe use.

FDA’s review to support the removal of the inperson dispensing requirement surpassed the statutory requirements. Under the governing statute,

FDA may approve a drug based on “data from one adequate and well-controlled clinical investigation and

confirmed evidence.” See 21 U.S.C. § 355 (d) (emphasis added). Removing a REMS requirement need only

be supported by an assessment and an “adequate rationale.” 21 U.S.C. § 355-1(g)(4)(A). Pursuant to

these statutory requirements, FDA regularly

5

approves drugs supported by only one clinical study.3

Here, FDA’s multiple analyses encompassed 25 highquality scientific studies, which together covered

more than 50,000 patient experiences, that overwhelmingly supported the conclusion that mifepristone is extremely safe and effective without the inperson dispensing requirement.

Moreover, FDA properly determined that the inperson dispensing requirement was not only unnecessary but also inconsistent with the statutory requirements for maintaining REMS elements. The statute

provides that elements to assure safe use within a

REMS must be “commensurate with [a] specific serious risk listed in the labeling of the drug,” and cannot

be “unduly burdensome on patient access to the drug,

considering in particular . . . patients who have difficulty accessing health care (such as patients in rural

or medically underserved areas).” 21 U.S.C. § 3551(f)(2). FDA correctly concluded that the REMS unduly burdened patients in light of studies demonstrating that the in-person dispensing requirement reduced access to mifepristone.

As set forth below, FDA acted in accordance with

the statutory requirements and ample conclusive scientific evidence in removing the in-person dispensing

requirement.

3 See Kaplan et al., Review of Evidence Supporting 2022 US Food

and Drug Administration Drug Approvals, 6 JAMA NETWORK

OPEN e2327650 (2023) (finding that 65% percent of approved

novel drugs in 2022 were supported by one clinical study).

6

A.

The April 2021 Decision to Not Enforce the In-Person Dispensing Requirement Was Supported by Substantial Scientific Evidence.

To support its 2021 nonenforcement decision,

FDA relied on studies that included clinical outcome

data for more than 50,000 patients who obtained medication abortion care.4 This literature studied the

safety and effectiveness of care delivered in person,

via telehealth, and through hybrid options—where

some but not all stages of care were provided in person.5 FDA determined that the “overall findings from

these studies do not appear to show increases in

safety concerns” when the medication is dispensed

through telehealth.6 Each study considered by FDA

identified high effectiveness and safety rates for the

provision of medication abortion care via telehealth,

with patient outcomes consistent with those associated with in-person dispensing of mifepristone. Thus,

FDA relied upon ample evidence that the in-person

dispensing requirement was not necessary to ensure

the safety and effectiveness of mifepristone.

One such study evaluated the TelAbortion Project, a pilot program through which patients could

4 Letter from Janet Woodcock, Acting Commissioner of Food &

Drugs, to Mauren Phipps, Chief Executive Official, Am. Coll. Of

Obstetricians & Gynecologists, and William Grobman, President, Soc’y for Maternal-Fetal Med. (Apr. 12, 2021), at 1 (hereinafter “April 2021 FDA Letter”).

5 Id.

6 Id. at 2.

7

obtain mifepristone by mail.7 The study found a 95%

abortion completion rate across the 1,157 patients for

whom it obtained pregnancy outcome information.8

This success rate is comparable to that established for

in-person care in prior scientific research.9 Only 0.9%

of telehealth patients experienced serious adverse

events, which is consistent with the rate of serious adverse events reported when mifepristone is dispensed

in person.10 The authors concluded that their “data

disprove[d] the notion that medication abortion must

be dispensed in-person[.]”11

Another study directly compared effectiveness

and safety rates for 334 patients obtaining medication

abortion via three methods: telehealth consultation

with pills sent by mail, telehealth consultation with

in-person medication pick-up, and in-person care consultation and medication pick-up.12 The study found

consistent effectiveness and “low rates of adverse

events” across all three cohorts, with fully remote

7 Id. at 1 (citing Chong et al., Expansion of direct-to-patient tele-

medicine abortion service in the United States and experience

during the COVID-19 pandemic, 104 CONTRACEPTION 43 (2021)).

8 Chong et al., supra note 7.

9 Id. (citing Chen et al., Mifepristone with Buccal Misoprostol for

Medical Abortion, a Systematic Review, 126 OBSTET. & GYNECOL.

12 (2015)).

10 Id.

11 Id. at 48.

12 April 2021 FDA Letter at 1 (citing Kerestes et al., Provision of

medication abortion in Hawai’i during COVID-19: Practical experience with multiple care delivery models, 104 CONTRACEPTION

49 (2021)).

8

patients reporting the highest rate of effectiveness

(97.1%).13

In addition to this robust body of evidence collected in the United States, FDA considered two international studies. The first study included data

from 52,142 patients obtaining abortions in England

and Wales during the two months before and after local COVID-related guidelines shifted medication

abortion care to a telehealth framework.14 The study

included data on 85% of all patients obtaining medication abortion in England and Wales during this period. The authors concluded that treatment success

was similar before and after the change in guidelines:

for the post-COVID cohort, 99.2% of telemedicine patients and 98.1% of in-person patients had complete

abortions, compared with 98.2% pre-COVID.15 Both

the pre- and post-COVID cohorts experienced extremely low rates of serious adverse events (.02% telehealth compared to .04% in clinic).16 The study also

found that telehealth increased access to care with

significant reductions in waiting times and pregnancy

duration at the time of termination.17 The second international study examined 663 Scottish patients and

found a 98% completion rate for patients who obtained an at-home medication abortion after a

13 Kerestes et al., supra note 12.

14 April 2021 FDA Letter at 1 (citing Aiken et al., Effectiveness,

safety and acceptability of no-test medical abortion (termination

of pregnancy) provided via telemedicine: a national cohort study,

128 BJOG 1464 (2021)).

15 Aiken et al., supra note 14.

16 Id.

17 Id.

9

telephone consultation.18 The patients’ low rate of serious adverse events (with only 2 patients total admitted to the hospital) was “similar to those after abortion care in a clinical setting.”19

B.

FDA Relied on and Discussed Additional Evidence in Its December

2021 Analysis Supporting the

Safety and Effectiveness of Removing the In-Person Dispensing Requirement.

In December 2021, FDA reviewed additional

studies that included more than 3,000 patients, and

further reviewed certain studies it examined in April

2021, all supporting the removal of the in-person dispensing requirement. All the studies found comparably high effectiveness rates and very low rates of serious adverse events between medication abortions dispensed in person and those obtained without an inperson visit.20

18 April 2021 FDA Letter at 1 (citing Reynolds-Wright et al., Tel-

emedicine medical abortion at home under 12 weeks’ gestation: a

prospective observational cohort study during the COVID-19

pandemic, 47 BMJ SEX. REPROD. HEALTH 246 (2021)).

19 Reynolds-Wright et al., supra note 18, at 247.

20 See Center for Drug Evaluation and Research, Application

Numbers: 020687 and 91178 Rationale Review (Dec. 16, 2021)

(hereinafter “FDA 2021 Rationale Review”); see also Letter from

Patrizia A. Cavazzoni, M.D., Director Center for Drug Evaluation and Research to Donna J. Harrison, M.D., Executive Director Am. Ass’n of Pro-Life Obstetricians & Gynecologists and

Quentin L. Van Meter, President, Am. Coll. of Pediatricians

denying in part and granting in part 2019 Citizen Petition at 2536 (Dec. 16, 2021).

10

Two of the newly reviewed studies were additional publications evaluating the TelAbortion Project

(see supra Section I.A), which again found very low

rates of serious adverse events and high completion

rates without the need for follow-up care.21 One identified a 94% completion rate with only two serious adverse events across 217 patients who received abortion medication by mail.22 The other identified a

95.6% completion rate and only three serious adverse

events across 412 patients who obtained abortion

medications by mail.23 The latter study also compared groups of patients who obtained a pretreatment

ultrasound or pelvic exam to those who did not and

identified no statistically significant differences in serious adverse events.

Three additional studies provided further evidence of the safety and effectiveness of the provision

of mifepristone without in-person dispensing at a hospital, clinic, or medical office. A U.S.-based study that

did not require a pre-abortion ultrasound collected

abortion outcomes for 110 patients who obtained medication abortion delivered by a mail-order pharmacy

after a telehealth evaluation of medical history and

21 FDA 2021 Rationale Review at 24, 28-29, 32, 34, 39 (discussing

Raymond et al., TelAbortion: evaluation of a direct to patient telemedicine abortion service in the United States, 100 CONTRACEPTION 173 (2019)); id. at 24, 28-30, 34, 39 (discussing Anger et al.,

Clinical and service delivery implications of omitting ultrasound

before medication abortion provided via direct-to-patient telemedicine and mail in the US, 104 CONTRACEPTION 659 (2021)).

22 Raymond et al. (2019), supra note 21.

23 Anger et al., supra note 21.

11

pregnancy.24 The study concluded that 95% of participants experienced a complete abortion with no need

for follow-up care, and no serious adverse events were

reported.25 A second study provided outcome data for

224 patients who were assessed in person before receiving medication through a mail-order pharmacy.26

The study identified a 96.9% completion rate and only

two serious adverse events—a rate comparable to the

serious-adverse-event rate reported in connection

with in-clinic care.27 The third study focused on Australia’s first nationwide telehealth abortion program

to not require an in-person visit to a provider.28 This

study included data for 754 patients who received

medication abortion through a mail-order pharmacy

and showed a 96% completion rate. While the study

found that 3% of patients were admitted to the hospital, the reasons for hospitalization are not discussed

by the authors. The study authors do note that the

24 FDA 2021 Rationale Review at 24, 27-28 (discussing Upadh-

yay et al., Safety and Efficacy of Telehealth Medication Abortion

in the US During the COVID-19 Pandemic, 4 JAMA NETWORK

OPEN e2122320 (2021)).

25 Upadhyay et al. (2021), supra note 24.

26 FDA 2021 Rationale Review at 24, 26, 28, 39 (discussing

Grossman et al., Mail-order pharmacy dispensing of mifepristone for medication abortion after in-person clinical assessment,

107 CONTRACEPTION 36 (2022)). This study is the interim analysis of the larger study cited infra note 48.

27 Grossman et al., supra note 26.

28 FDA 2021 Rationale Review at 24, 27-28, 39 (discussing Hyland et al., A direct-to-patient telemedicine abortion service in

Australia: Retrospective analysis of the first 18 months, 58

AUSTL. & N.Z. J. OBSTET. & GYNECOL. 335 (2018)).

12

majority of telehealth patients (60%) lived outside of

major cities.29

Based on the record of scientific evidence considered by FDA for its April 2021 nonenforcement decision and its December 2021 analysis, FDA reasonably

concluded that removing the in-person dispensing requirement would not reduce the safety or effectiveness of mifepristone for use in medication abortion.

C.

Additional Evidence Issued Before

FDA’s 2023 Final Decision Supports

the Safety and Effectiveness of Removing the In-Person Dispensing

Requirement.

FDA’s 2021 decision to remove the in-person dispensing requirement was formalized in 2023. Before

the agency’s final decision, additional studies were

published that demonstrated medication abortion via

telehealth continued to be safe and effective, with low

rates of serious adverse events similar to those arising out of in-person dispensing.

One such study examined a cohort of 3,779 patients across 24 states who received medication abortion in outpatient and online clinics.30 This study

highlighted high rates of effectiveness and low rates

of serious adverse events, regardless of whether the

medication was dispensed in person or mailed to the

patient.31 A study of nearly 280,000 patients in

29 Hyland et al., supra note 28, at 335.

Upadhyay et al., Outcomes and Safety of History-Based

Screening for Medication Abortion: A Retrospective Multicenter

Cohort Study, 182 JAMA INTERNAL MED. 482 (2022).

31 Id.

30

13

Canada conducted before and after that country eliminated its REMS-like restrictions on mifepristone to

make it available by prescription like other medications identified no material changes in the incidence

of serious adverse events compared to the period before the restrictions were lifted.32

D.

Plaintiffs Incorrectly Suggest That

FDA Ignored Studies Showing Remote Dispensing Might Lead to

More Emergency-Room Follow-Up

Visits.

The Fifth Circuit incorrectly concluded that

“FDA’s ‘own documents’ show that ‘emergency room

care is statistically certain’ in mifepristone cases.”

App. 11a (quoting All. for Hippocratic Med., 2023 WL

2913725, at *10 (5th Cir. Apr. 12, 2023)).33 This argument conflates emergency room visits with serious

adverse events and obfuscates research into the reasons underlying emergency room visits after a medication abortion. While FDA reviews information

about emergency room visits related to medication

abortion, it considers whether those visits are accompanied by other serious adverse events when evaluating real-world safety and effectiveness.34 Research

32 Schummers et al., Abortion Safety and Use with Normally Pre-

scribed Mifepristone in Canada, 386 N. ENG. J. MED. 57 (2022).

33 “App.” refers to the Appendix to the Application by Danco to

Stay or Vacate the Fifth Circuit's Stay Pending Appeal.

34 U.S. FOOD AND DRUG ADMINISTRATION, What is a Serious Adverse Event? (May 18, 2023), https://www.fda.gov/safety/reporting-serious-problems-fda/what-serious-adverse-event (hereinafter “FDA, What is a Serious Adverse Event?”) (“Emergency room

14

shows that patients go to an emergency room after a

medication abortion for reassurance, for symptom

evaluation, to ask questions, or to confirm they are no

longer pregnant, without receiving any treatment.35

As many as half of all emergency room visits receive

observation care only without treatment.36 Emergency room visit rates therefore are not a reliable

proxy for the safety or effectiveness of mifepristone.

E.

FDA Properly Relied on Adverse

Event Reporting to Conclude That

Removing the In-Person Dispensing Requirement Would Not Compromise Patient Safety.

FDA’s reliance on adverse event reporting data

was both appropriate and consistent with its statutory authority and with standard agency practice.

FDA reviewed the FDA Adverse Event Reporting System (“FAERS”) data for January 27, 2020, through

September 30, 2021—a period that included intervals

when the in-person dispensing requirement both was

and was not enforced. FDA’s analysis, along with its

continuous monitoring of real-world adverse-event

visits that do not result in admission to the hospital should be

evaluated for one of the other serious outcomes (e.g., life-threatening; required intervention to prevent permanent impairment

or damage; other serious medically important event.”).

35 See, e.g., Upadhyay et al., Incidence of Emergency Department

Visits and Complications After Abortion, 125 OBSTET. & GYNECOL. 175 (2015); Upadhyay et al., Abortion-related emergency

department visits in the United States: An analysis of a national

emergency department sample, 16 BMC MED. 88 (2018).

36 Upadhyay et al., Abortion-related emergency department visits

in the United States: An analysis of a national emergency department sample, 16 BMC MEDICINE 88 (2018).

15

data, identified no safety concerns.37 FDA analyzed

seven instances of adverse events. While five of the

seven were reported when the in-person dispensing

requirement was not enforced, three of those five

cases involved circumstances where mifepristone was

dispensed in person.38 FDA analyzed this data to determine whether there was any difference in adverse

events between the two periods and found none, concluding that “mifepristone may be safely used without

an in-person dispensing requirement.”39

The Fifth Circuit concluded that Plaintiffs are

likely to succeed on the merits because FDA’s reliance

on the FAERS data was inappropriate. App. at 13a.

This argument misunderstands the 2016 reporting

modification. The change eliminated only an unusual

requirement that prescribers separately report certain non-fatal adverse events to manufacturers. Absent the requirement, manufacturers must still review, collect, and submit all adverse drug experience

information received from prescribers in periodic reports to FDA. 21 C.F.R. § 314.80. Critically, FDA determined that serious adverse events other than

death would still be captured through these periodic

safety reports—the same reporting mechanism FDA

relies on for virtually all other prescription drugs.40

What’s more, FDA still maintains a heightened

37 FDA 2021 Rationale Review at 22-23; FDA 2023 Rationale Re-

view.

38 Id.

39 Id. at 23.

40Id.; see also FAERS Public Dashboard – FAQ, FDA

https://fis.fda.gov/extensions/FPD-FAQ/FPD-FAQ.html (FAERS

“supports the FDA’s post-marketing safety surveillance program” for all marketed drug products).

16

reporting requirement that prescribers report any potentially associated fatalities.41

In any event, the FAERS data was only one component of FDA’s analysis. The peer-reviewed scientific studies that FDA reviewed—covering tens of

thousands of patient outcomes, with data collected

through rigorous study designs—provided an independently sufficient evidentiary basis for FDA’s conclusion. See supra Section I.A. Plaintiffs’ focus on the

FAERS data ignores the overwhelming body of clinical evidence supporting the safety of removing the inperson dispensing requirement.

II.

The Body of Scientific Evidence Published Since 2023 Further Confirms the

Safety and Effectiveness of Medication

Abortion Without an In-Person Dispensing Requirement

A.

Additional Scientific Evidence

Lends Further Support for Removing the In-Person Dispensing Requirement.

The scientific evidence collected and published

since 2023 has only further confirmed the safety and

effectiveness of removing the in-person dispensing requirement. For example, a large-scale study of over

Information about Mifepristone for Medical Termination of

Pregnancy Through Ten Weeks Gestation, FDA (Jan. 17, 2025),

https://www.fda.gov/drugs/postmarket-drug-safety-informationpatients-and-providers/information-about-mifepristone-medical-termination-pregnancy-through-ten-weeks-gestation

(providing mifepristone’s current REMS and prescriber agreement form).

41

17

6,000 patients obtaining medication abortions via

telehealth found 97.7% effectiveness and a seriousadverse-effect rate of only 0.25%, with no significant

differences between synchronous and asynchronous

models of care.42 Another 2024 study that examined

outcomes for patients obtaining telehealth medication

abortion with a concurrently recruited cohort of patients who obtained in-person care in the same clinic

systems found no difference between the two groups

in the effectiveness of the abortion care or rates of serious adverse events.43 The overall effectiveness rate

was 94.4% for the no-test-and-mail group and 93.3%

for the in-person-with-ultrasonography group.44 Further, a June 2025 Cochrane Review found that “the

use of telemedicine for medical abortion in early pregnancy is generally safe, effective, and acceptable”; the

review’s findings were “consistent with the conclusions of previous work on the topic,” including “more

recent non-comparative studies.”45 The report concluded that “serious adverse events are rare” when

medication abortions are obtained without an in-person dispensing requirement.46

42 Upadhyay et al., Effectiveness and safety of telehealth medica-

tion abortion in the USA. 30 NATURE MED. 1191 (2024).

43 Ralph et al., Comparison of No-Test Telehealth and In-Person

Medication Abortion, 322 JAMA 898 (2024). Synchronous care

involves real-time video conferencing or telephone calls between

a patient and provider; asynchronous care involves an intake

form or app through which patients can submit information for

the provider to view at a later time.

44 Id.

45 Cleeve et al., The use of telemedicine services for medical abortion, 4 COCHRANE DATABASE SYSTEMIC REVS. 1, 25 (2025).

46 Id. at 10.

18

Another study with 184 medication abortion patients compared in-clinic care to telehealth-care-withmedication-mailing and concluded that telehealth is

“as effective, timelier, and potentially more accessible

than in-clinic” care.47 Similarly, a study of 510 medication abortions where eligibility was assessed

through an in-person visit but patients received medication through a mail-order pharmacy identified

97.8% effectiveness and only three serious adverse

events.48 Yet another study showed that “medication

abortion care provided without screening ultrasonography or pelvic examination is comparably safe and

effective to care with these screening tests.”49 And a

pilot project in Colorado and Minnesota with 156 patients studying the feasibility and safety of a self-administered, programmed questionnaire to screen for

medication abortion eligibility showed a 95% abortion

completion rate and few adverse events.50

47 Srinivasulu et al., Telehealth Medication Abortion in Primary

Care: A Comparison to Usual in-Clinic Care, 37 J. AM. BOARD

FAM. MED. 295, 295 (2024).

48 Grossman et al., Mail-Order Pharmacy Dispensing of Mifepristone for Medication Abortion After In-Person Screening, 184

JAMA INTERN. MED. 873 (2024).

49 Koenig et al., Effectiveness and safety of medication abortion

with vs without screening ultrasonography or pelvic examination, 233 AM. J. OBSTETRICS & GYNECOLOGY 453 (2025); see also

Hunter et al., Test or No-Test: Comparison of Medication Abortion Outcomes and Adverse Events When Forgoing Ultrasound,

Laboratory Testing, and Physical Examination, 47 J. OBSTET. &

GY CAN. 102730 (2024) (showing similar results in Canada).

50 Raymond et al., Evaluation of a “smart” screening tool for asynchronous assessment of medication abortion eligibility: A pilot

study, 131 CONTRACEPTION 110340 (2024); see also Smith, The

19

Telehealth dispensing is also critical for patient

access. A recent study found that telehealth averted

significant travel time—saving one hour and twentyfive minutes for public-transportation users—and

particularly benefitted younger patients, those living

in rural areas, those experiencing food insecurity, and

those living far from the nearest abortion facility.51

Patients also report widespread satisfaction with remote dispensing: a recent study showed that 98% of

patients trusted their telehealth provider, and 96%

felt telehealth was the right decision.52 Patients most

commonly cited privacy and expediency as primary

benefits.53

These studies confirm what FDA knew to be true

in 2021 and 2023: telehealth dispensing of mifepristone is safe, effective, and reduces burdens to accessing care.

Safety and Efficacy of a “No Touch” Abortion Program Implemented in the Greater Toronto Area During the COVID-19 Pandemic, 46 J. OBSTET. & GYN. CAN. 102429 (2024) (assessing results for a similar program in the Toronto area).

51 Koenig et al., The Role of Telehealth in Promoting Equitable

Abortion Access in the United States: Spatial Analysis, 9 JMIR

PUB. HEALTH AND SURVEILLANCE e45671 (2023); see also Koenig

et al., Mailing abortion pills does not delay care: A cohort study

comparing mailed to in-person dispensing of abortion medications in the United States, 121 CONTRACEPTION 109962 (2023)

(finding that patients obtaining mifepristone via telehealth can

access care just as quickly as patients obtaining mifepristone in

person).

52 Koenig et al., Patient Acceptability of Telehealth Medication

Abortion Care in the United States, 2021‒2022: A Cohort Study,

114 AM. J. PUB. HEALTH 241 (Feb. 2024).

53 Id.

20

B.

Plaintiffs Have Not Identified Any

Sound Science Undercutting the

Decision to Remove the In-Person

Dispensing Requirement.

Against the overwhelming scientific and medical

consensus that informed FDA’s reasoned decisionmaking, Plaintiffs lean on a self-published report by

the Ethics and Public Policy Center (“EPPC”). But

this report does not cast doubt on FDA’s decision to

remove the in-person dispensing requirement because it is riddled with methodological flaws that render its conclusions unreliable.

As an initial matter, EPPC has refused to disclose

the specific insurance claims database it utilized, the

methodology for identifying medication abortions, or

the coding it used to generate the study cohort and

analyze the data.54 This fundamental lack of transparency precludes any independent verification or reproducibility—fatal deficiencies for any scientific

analysis. Indeed, the report falls far short of the gold

standard science requirements defined by recent Executive Orders and White House Office of Science and

Technology Policy guidance, which require that data

and methods be “reproducible,” “transparent,” “communicative of error and uncertainty,” “skeptical of its

54 EPPC repeatedly told journalists it could not reveal the da-

taset or even its source. See, e.g., Kessler, Digging Into the math

of a study attacking the safety of the abortion pill, WASH. POST

(May

12,

2025),

https://www.washingtonpost.com/politics/2025/05/12/abortion-pill-medication-abortion-study-mifepristone; Landman, A Convenient Piece of Junk Science, ATLANTIC, (May 24, 2025), https://www.theatlantic.com/health/archive/2025/05/mifepristone-abortion-rfk-fda/682939.

21

findings and assumptions,” and “subject to unbiased

peer review.”55 EPPC’s report satisfies none of these

criteria.

Beyond these transparency failures, EPPC’s report systematically overestimates the number of serious adverse events associated with medication abortions obtained without an in-person dispensing requirement through a series of fundamental classification errors:

First, EPPC’s largest category of serious adverse

event is a vague catch-all category of “[o]ther abortion

complications,” which is likely where EPPC included

unidentified “codes suggested by our doctors.”56 However, EPPC provides no information whatsoever

about the training or expertise of the individuals who

did the coding, or what they relied upon to designate

complications for this category. EPPC also does not

disclose the codes that it counted in this “Other” category.57

Second, hemorrhage accounts for a significant

number of EPPC’s claimed “serious adverse events”

and the term is inadequately defined by EPPC.58

55 Executive Order, Restoring Gold Standard Science (May 23,

2025),

https://www.whitehouse.gov/presidential-actions/2025/05/restoring-gold-standard-science.

56 Hall et al., The Abortion Pill Harms Women: Insurance Data

Reveals One in Ten Patients Experiences a Serious Adverse

Event, ETHICS & PUB. POL’Y CTR. (2025), 2, 5,

https://eppc.org/publication/insurance-data-reveals-one-in-tenpatients-experiences-a-serious-adverse-event

(hereinafter

“EPPC Report on Serious Adverse Event”).

57 See id.

58 Id. at 2.

22

Because a successful medication abortion always involves bleeding, EPPC more likely than not misclassified cases of normal, expected bleeding as serious

adverse events.59

Third, EPPC included emergency room visits as

serious adverse events,60 even though—as discussed

above—research consistently shows that many emergency room visits following medication abortion are

for routine symptom assessment and do not result in

any treatment. FDA has also determined that an

emergency-room visit, in and of itself, is not a serious

adverse event.61

Fourth, EPPC counted circumstances where patients sought treatment to complete a medication

abortion as a serious adverse event. That approach is

inconsistent with published literature and FDA guidance. The need for additional medications or a procedure to complete an abortion is an expected outcome

in 3-5% of patients.62 Any additional medications can

be dispensed remotely and the procedure to complete

the abortion can be administered in a doctor’s office or

outpatient clinic.

Fifth, EPPC purported to identify instances of

medication abortions by identifying prescriptions for

mifepristone with or without misoprostol within the

59 See Arey, Self-diagnosing the end of pregnancy after medica-

tion abortion, 26 CULT. HEALTH SEX. 405 (2024).

60 EPPC Report on Serious Adverse Event at 5.

61 FDA, What is a Serious Adverse Event?

62 Chen et al., supra note 9; Raymond et al., First-trimester medical abortion with mifepristone 200 mg and misoprostol: A systematic review, 87 CONTRACEPTION 26 (2013); Upadhyay et al.

(2015), supra note 35.

23

next three days. But mifepristone and misoprostol

are also used for miscarriage management, which is

associated with a slightly higher complication rate

than for abortion. EPPC’s method of identifying abortions therefore artificially inflates the serious-adverse-event rate.63

Sixth, insurance claims databases systematically

overrepresent patients more likely to have pregnancy

complications, because some insurance plans—particularly Medicaid—provide coverage for abortion care

only when the pregnancy endangers the life of the

pregnant person or in instances of rape or incest,

meaning patients with higher risk profiles are disproportionately captured in the data.64

Even setting aside these pervasive methodological flaws, EPPC’s sweeping conclusions and policy

recommendations are not even supported by its own

supposed evidence. In its report, EPPC argues that

in-person dispensing would reduce serious adverse

events.65 Yet, the report does not differentiate its

63 EPPC Report on Serious Adverse Event at 4; see, e.g., Boos et

al., Trends in the Use of Mifepristone for Medical Management of

Early Pregnancy Loss From 2016 to 2020, 330 JAMA 766 (2023);

Tarleton et al., Society of Family Planning Clinical Recommendation: Medication management for early pregnancy loss, 144

CONTRACEPTION 110805 (2025); Nobles et al., Abortion Restrictions Threaten Miscarriage Management In The United

States, 43 HEALTH AFFAIRS (MILLWOOD) 1219 (2024); Schreiber

et al., Mifepristone Pretreatment for the Medical Management of

Early Pregnancy Loss, 378 N. ENGL. J. MED. 2161 (2018).

64 Frederiksen et al., The limitations of using Medicaid administrative data in abortion research. 142 CONTRACEPTION 110704

(2025).

65 EPPC Report on Serious Adverse Event at 2.

24

alleged serious adverse events by the dispensing location or by year, so there is no support for its claim that

removing the in-person dispensing requirement has

increased serious adverse event rates.66

EPPC’s attempt to salvage its conclusions in a

hastily written Q&A document posted days before filing its amicus brief at the district court—subsequently converted to a fact sheet—fares no better. In

that document, EPPC compared the rate of alleged serious adverse events before and after July 2020—

when FDA’s in-person dispensing requirement was

temporarily paused by court order—claiming that the

data show a statistically significant higher rate of serious adverse events in the second time period.67

Telehealth is likely not the cause of any such increase. Because most telehealth providers did not accept insurance during this period, the vast majority of

telehealth abortions would not be captured in EPPC’s

dataset.68 EPPC admits it does not even have data on

66 Similarly, although EPPC’s analysis does not examine adverse

events by pregnancy duration or whether mifepristone was provided by a physician or an advanced practice clinician, EPPC

opines on gestational limits and recommends that only physicians provide mifepristone. EPPC Report on Serious Adverse

Event at 2.

67 See Hall et al., Fact Sheet: Data Reveals the FDA’s Removal of

In-Person Dispensing Requirement Increased the Dangers of the

Abortion Pill, ETHICS & PUB. POL’Y CTR. (2026), https://media.eppc.org/2026/03/FACT-SHEET-Data-on-FDA-Removal-ofIn-person-dispensing-requirement-2.pdf.

68 See Koenig et al., Virtual Clinic Telehealth Abortion Services

in the United States One Year After Dobbs: Landscape Review,

26 J. MED INTERNET RES. e50749 (2024) (of 20 virtual clinics

25

the number of medication abortions administered remotely after July 2020.69

Ultimately, the fundamental flaws in EPPC’s

methodology—particularly its expansive and scientifically unsupported classification of “serious adverse

events”—fatally undercut any claims regarding an increase in adverse events. EPPC’s report does not constitute the kind of rigorous, transparent, peer-reviewed science on which regulatory decisions should

be based, and it provides no basis whatsoever for this

Court to second-guess FDA’s expert judgment, based

on a voluminous record of sound scientific studies, to

remove the in-person dispensing requirement.

providing telehealth abortion care in 26 states and Washington

D.C. in June 2023, only two accepted private insurance and one

accepted Medicaid); Upadhyay et al., Pricing of medication abortion in the United States, 2021-2023, 56 PERSPECTIVES ON SEX.

AND REPROD. HEALTH 282 (2024) (“Most virtual clinics did not

accept Medicaid. In 2021, none of the 31 (0%) virtual clinics accepted Medicaid, increasing to 16 out of 226 (7%) in 2023.”).

69 Society of Family Planning, #WeCount Report April 2022

through June 2025, (Dec. 9, 2025), https://societyfp.org/wecountreport-10-june-2025-data.

26

CONCLUSION

For the foregoing reasons, the Court should reverse the Fifth Circuit’s decision.

Respectfully submitted,

Amanda Barrow

Cathren Cohen

Sofia Espinoza

Melissa Goodman

Diana Kasdan

CENTER ON REPRODUCTIVE

HEALTH, LAW, AND POLICY

UCLA SCHOOL OF LAW

1060 Veteran Avenue

Los Angeles, CA 90095

(310) 267-4382

May 6, 2026

Alexander N. Ely

Counsel of Record

Doménica A. Merino

Quynhanh N. Tran

O’MELVENY & MYERS LLP

1625 Eye Street, N.W.

Washington, DC 20006

(202) 383-5400

aely@omm.com

Leah Godesky

O’MELVENY & MYERS LLP

1999 Avenue of the Stars

Los Angeles, CA 90067

(310) 553-6700

APPENDIX

APPENDIX TABLE OF CONTENTS

Page

APPENDIX: List of Amici Reproductive Health

Researchers .....................................

1a

1a

APPENDIX

List of Amici

Reproductive Health Researchers1

Alice Abernathy, MD, MSHP, Assistant Professor

of Obstetrics and Gynecology, Medical Ethics and

Health Policy, Leonard Davis Institute of Health

Economics, University of Pennsylvania

Abigail Aiken, MD, MPH, PhD, Associate Professor

of Public Affairs, University of Texas at Austin

Clayton Alfonso, MD, FACOG, Associate Professor,

Duke Univeristy

Amy Alspaugh, PhD, MSN, Assistant Professor,

University of Tennessee

Anna Altshuler, MD, MPH, Associate Professor &

Researcher, University of California, San Francisco

Stephanie Amaya, MD, Clinical Professor,

Researcher, Medical Director, University of Arizona

Karen Antell, MD, MPH, Family Medicine and

OBGYN Faculty Physician, ChristianaCare

Amanda Antonio,

Parenthood of Florida

MD,

Physician,

Planned

Andrea Arena, MD, Professor, Brown University

Whitney Arey, PhD, Researcher, University of

North Carolina at Chapel Hill

1 The listed institutions are the current places of employment of

the amici. The institution is listed for identification purposes

only and the views expressed in this brief do not necessarily

reflect the views of amici’s affiliated institutions.

2a

Stephanie Arteaga, MPH, Research Project

Director / Doctoral Candidate, University of

California, Berkeley / University of California, San

Francisco

Ifeyinwa Asiodu, PhD, MS, BSN, Associate

Professor, University of California, San Francisco

Sam Auerbach, PhD, WHNP, Postdoctoral Fellow,

University of California, San Francisco

Amy M. Autry, MD, Professor, University of

California, San Francisco

Sarah Averbach, MD, MAS, Professor, University

of California, San Diego

C. Finley Baba, MPH, Project Director, Advancing

New Standards in Reproductive Health, University of

California San Francisco

Lela Bachrach, MD, MS, Clinical Professor,

University of California, San Francisco

Elena Rhoads Baeza, MD, PhD, Assistant Clinical

Professor, Director of Perinatal Quality and Safety,

University of California Irvine

Meisha Baker, MD, Complex Family Planning

Fellow, Icahn School of Medicine at Mount Sinai

Maureen K. Baldwin, MD, MPH, Associate

Professor of OBGYN, Oregon Health & Science

University

Jill Barr-Walker, MPH, MS, Clinical Librarian,

University of California, San Francisco

Deborah Bartz, MD, MPH, Associate Professor,

OBGYN, Harvard Medical School/Brigham and

Women's Hospital

3a

Maya Bass, MD, MA, FAAFP, Program Director,

Assistant Professor, Cooper

Molly Battistelli, MPH, Director of Administration

& Policy, University of California, San Francisco

Sarah Baum, MPH, Researcher, Ibis Reproductive

Health

Lisa Bayer, MD, MPH, Associate Professor, Oregon

Health & Science University

Suzanne O. Bell, PhD, Associate Professor, Johns

Hopkins University

Michael A. Belmonte, MD, Assistant Professor of

Obstetrics and Gynecology, Penn State University

Ariana Bennett, DrPH, MPH, Postdoctoral

Scholar, University of California, Berkeley

Nancy F. Berglas, DrPH, Associate Professor,

University of California, San Francisco

Elise Berlan, MD, MPH, Professor, Ohio State

University

Caitlin Bernard, MD, MSCI, FACOG, Associate

Professor, Indiana University school of medicine

Danielle Bessett, PhD, Professor of Sociology,

University of Cincinnati

Antonia Biggs, PhD, Professor, University of

California, San Francisco

Dawn Bingham, MD, MPH, FACOG, Associate

Professor, Yale New Haven Hospital

Kayla Blair, MD, MPH, Resident, University of

California, San Francisco

4a

Kelly Blanchard, MSc, President, Ibis Reproductive

Health

Paul Blumenthal, MD, MPH, Professor Emeritus,

Stanford University

Christy Boraas, MD, MPH, Associate Professor,

University of Minnesota

Sonya Borrero, MD, MS, Professor of Medicine,

CONVERGE, University of Pittsburgh

Michel Boudreaux, PhD, Associate Professor,

University of Maryland

Kari P. Braaten, MD, MPH, Assistant Professor of

Obstetrics and Gynecology, Mass General Brigham

Dalia Brahmi, MD, MPH, Physician and Family

Planning Specialist, Planned Parenthood South

Atlantic and University of North Carolina

Caila Brander, MSc, Senior Research Manager, Ibis

Reproductive Health

Kristyn Brandi, MD, MPH, FACOG, Co-Founder,

Luminosas Wellness Collective

Sha'llah Brewton,

Healthcare

MD,

Physician,

SBMD

Claire Brindis, DrPH, Distinguished Professor,

University of California, San Francisco

Kathleen Broussard, PhD, Professor, University of

South Carolina

5a

Benjamin P. Brown, MD, MS, Mimi Pichey

Assistant Professor of Obstetrics and Gynecology, and

Assistant Professor of Health Services, Policy, and

Practice, Clinician Educator, The Warren Alpert

Medical School and the School of Public Health,

Brown University

Katherine Brown, MD, MAS, Associate Professor,

University of California, San Francisco

Amanda Bryson, MD, MPH, Assistant Professor,

University of California, San Francisco

Mara Buchbinder, PhD, Professor and Chair, UNC

Chapel Hill

Brooke W. Bullington, PhD, Postdoctoral fellow,

University of Utah

Bhaskari Burra, MD, Maternal Fetal Medicine

Physician, Mountain Area Health Education Center

Alice Cartwright, PhD, MPH, Senior Research

Scientist, Guttmacher Institute

Diana Carvajal, MD, MPH, Physician researcher,

University of Wisconsin School of Medicine and Public

Health

Philicia W. Castillo, MPH, Researcher, CUNY

School of Public Health

Neko Castleberry, PhD, Research Data Analyst,

UCLA

Laura Castleman, MD, MPH, MBA, Associate

Medical Director, Planned Parenthood Michigan

6a

Wendy Chavkin, MD, MPH, Professor Emerita

Public Health and Obstetrics Gynecology, Columbia

University Irving Medical Center and Mailman

School Public Health

Beatrice Chen, MD, MPH, Associate Professor,

University of Pittsburgh

Cynthia Chuang, MD, Professor of Medicine, Penn

State Health

Kelly Cleland, MPA, MPH, Executive Director,

American Society for Emergency Contraception

Francine Coeytaux, MPH, Co-Founder, Plan C

Craig Cohen, MD, MPH, Professor, University of

California, San Francisco

Kate Coleman-Minahan, PhD, RN, FNP-BC,

Associate Professor, University of Colorado Anschutz

Medical Campus

Kimberly Coleman-Phox, MPH,

University of California, San Francisco

Researcher,

Alyssa Colwill, MD, MCR, Associate Professor,

Ob/Gyn, OHSU

Sarah Combellick, PhD, MPH, Research Scientist,

Independent Researcher

Chiara Corbetta-Rastelli, MD, Fellow, University

of California, San Francisco

Allison Cowett, MD, MPH, Chief Medical and

Advocacy Officer, Family Planning Associates

Medical Group

Chris Creatura, MD, Assistant Professor of

Obstetrics and Gynecology, Weill-Cornell Medical

College

7a

Mitchell Creinin, MD, Distinguished Professor of

Obstetrics and Gynecology, University of California

Davis Health

Halley Crissman, MD, MPH, Adjunct Clinical

Assistant Professor of Obstetrics and Gynecology,

University of Michigan

Kathryn R. Crofton, MD, CFP Fellow, RUSH

Lara Crystal-Ornelas, MD, MAS, Physician

Sara Daniel, PhD, MPH, Postdoctoral Fellow,

University of Maryland Baltimore School of

Pharmacy

Chelsea Daniels, MD, Family Planning Staff

Physician, Planned Parenthood

Blair G. Darney, PhD, MPH, Vice President for

Domestic Research, Guttmacher Institute

Christine Dehlendorf, MD, MAS,

University of California San Francisco

Professor,

Amanda Dennis, DrPH, Executive Director, Society

of Family Planning

Sheila Desai, DrPH, MPH, Research Director,

Coalition to Expand Contraceptive Access

Divya Dethier, MD, Associate Physician, Kaiser

Permanente San Francisco

Nadia Diamond-Smith, PhD, MSc, Associate

professor, University of California San Francisco

Shokoufeh Dianat, DO, MAS, FAAFP, Family

Physician, Family Planning Specialist, Dandelion

Health

8a

Samuel Dickman, MD, Researcher,

Research for Reproductive Health

Resound

Justin Diedrich, MD, MSCI, Physician, Eden

Surgical

Alesha Doan, PhD, Professor, University of Kansas

Celina Doria, PhD, MSW, Assistant Professor,

University of Wisconsin-Madison

Eleanor Drey, MD, Professor,

California, San Francisco

University

of

Hayley Dunlop, MD, MPH, Resident Physician,

University of California, San Francisco

Alison Edelman, MD, MPH, Professor, OHSU

Schyler Edwards, MD, MA, Resident Physician,

University of California, San Francisco

Katherine Ehrenreich, MSc, Project Director,

University of California San Francisco

J. Shoshanna Ehrlich, JD, Professor Emerita,

University of Massachusetts Boston

David

Eisenberg,

MD,

MPH,

Professor,

Washington University in St. Louis School of

Medicine

Jackie Ellison, PhD,

University of Pittsburgh

Assistant

Professor,

Margit Endler, MD, PhD, Associate Professor,

Karolinska Institutet

Priyal Fadadu, MD, MS, Fellow, Researcher,

University of Washington

Laura Ferguson, PhD, Associate

University of Southern California

Professor,

9a

Anna E. Fiastro, PhD, MPH, MEM, Research

Scientist, University of Washington

Sofia Filippa, MPH, Doctoral Fellow, Emory

University

Susan Fisher, PhD, Professor, University of

California, San Francisco

Catherine S.

Emeritus, CA

Forest,

MD,

MPH,

Professor

Angel M. Foster, DPhil, MD, AM, Professor and

University Research Chair in Medication Abortion

Studies, University of Ottawa

Diana Greene Foster, PhD, Professor, University

of California, San Francisco

Dov Fox, LLM, JD, DPhil, Professor, University of

San Diego School of Law

Linda Franck, PhD, RN, Professor, University of

California San Francisco

Lori Freedman, PhD, Professor, University of

California, San Francisco

Valerie French, MD, MAS, Professor, University of

Kansas

Juliana Friend, PhD, MPhil, Postdoctoral

Researcher, University of California, San Francisco

Lori Frohwirth, BA, Qualitative Surveillance

Manager, New York City Department of Health and

Mental Hygiene

Laura Frye, MPH, Researcher, Rutgers School of

Public Health

10a

Liza Fuentes, DrPH, MPH, Public Health Scientist,

Independent Scholar

Sara Fuhrman, MD, MA, Fellow, UC Irvine

Maria Gallo, PhD, Professor, University of North

Carolina at Chapel Hill

Brandon Ganjineh, MD, Resident

University of California, San Francisco

Keri Garel,

University

Physician,

MD, Assistant Professor, Boston

Aileen Gariepy, MD, MPH, MHS, Associate

Professor, Director of Complex Family Planning,

Weill Cornell Medicine

Cory Ellen Gatrall, PhD, RN, Postdoctoral Fellow,

University of California San Francisco

Meghan Geary, MD, Assistant Professor of

Medicine, The Warren Alpert Medical School of

Brown University

Asmara Gebre, MSN, Program Director, Midwife,

University of California, San Francisco

Kristina

Gemzell-Danielsson,

Professor, Karolinska Institutet

MD,

PhD,

Caitlin Gerdts, MHS, PhD, Vice President for

Research, Ibis Reproductive Health

Adrienne Ghorashi, JD, Law and Policy Analyst

(Researcher/Lawyer), Center for Public Health Law

Research

Margaret Giorgio, PhD, MPH, Principal Research

Scientist, Guttmacher Institute

11a

Jessica Gipson, MPH, PhD, Professor, Bixby Chair

of Population and Reproductive Health, Director,

UCLA Bixby Center to Advance Sexual and

Reproductive Health Equity, UCLA Fielding School of

Public Health

Natalie Gladstein, MD, MSc, OB/GYN Professor,

Detroit Medical Center

Emily M. Godfrey, MD, MPH, Professor of Family

Medicine and Obstetrics and Gynecology, University

of Washington

Marji Gold, MD, Professor of Family and Social

Medicine; Researcher, Albert Einstein College of

Medicine

Alisa B. Goldberg, MD, MPH, Associate Professor,

Obstetrics, Gynecology & Reproductive Biology,

Harvard Medical School, Mass General Brigham

Anu Manchikanti Gomez, PhD,

University of California, Berkeley

Professor,

Rebvca Gomperts, MD, MPP, PHD, Director, Aid

Access

Maria Isabel Gonzaga, MD, Fellow, USC

Joel R. Gonzalez, MPH, MPP, Research Associate,

University of California, San Francisco

Suzan Goodman, MD, MPH, Clinical Professor;

Curriculum Director, University of California, San

Francisco

Heather Gould, MPH, Project Director, University

of California, San Francisco

Melissa Grant, BA, Chief Operations Officer,

carafem

12a

Beverly Gray, MD, Professor, Duke University

Medical Center

Daniel Grossman, MD, Professor, Advancing New

Standards in Reproductive Health, University of

California San Francisco

Sofia Gruskin, JD, MIA, Professor and Director,

Institute on Inequalities in Global Health, University

of Southern California

Pratima Gupta, MD, MPH, Associate Professor,

University of California, San Diego

Hillary Gyuras, MA, Senior Research Associate,

University of Cincinnati

Jill Hagey, MD, MPH, Assistant Professor, Duke

University

Tabetha R. Harken, MD,

University of California, Irvine

MPH,

Professor,

Cynthia Harper, PhD, Professor, University of

California, San Francisco

Elizabeth K. Harrington, MD, MPH, Assistant

Professor, Researcher, University of Washington

S. Marie Harvey, MPH, DrPH, Professor, Oregon

State University

Asha Hassan, PhD, MPH, Professor, University of

Minnesota Medical School

Lee Hasselbacher, JD, Research

Professor, University of Chicago

Assistant

Jen Hastings, MAT, MD, Consultant Researcher,

Ibis Reproductive Health

13a

Luciana E. Hebert, PhD, Associate Professor,

Washington State University

Jillian

Henderson,

PhD,

MPH,

Senior

Investigator, Kaiser Permanente Center for Health

Research

Catherine Hennessey, MD, Assistant Professor,

Weill Cornell Medicine

Stephanie Herold, MPH, Researcher, University of

California, San Francisco

Jenny A. Higgins, PhD, MPH, Professor,

University of Wisconsin School of Medicine and Public

Health

Miranda Hill, PhD, Assistant Professor, University

of California, San Francisco

Stephanie Ho, MD, MPH, OB/GYN Physician,

Alameda Health System

Nuriye Sahin Hodoglugil, PhD, Clinical Research

Manager, University of California, San Francisco

Kelsey Holt, DSc, Associate Professor, University of

California

Sarah Horvath, MD, MSHP, Associate Professor

and Vice Chair for Research, Penn State Hershey

Medical Center

Melody Y. Hou, MD, MPH, Professor, Senior

Associate Dean, University of California, Davis

Rafa Ifthikhar, MD, Complex Family Planning

Fellow, University of California, San Francisco

Andrea Jackson, MD, MAS, Professor and Chair,

CA

14a

Christine Jackson, DO, MPH, Clinical Fellow,

Washington University in St. Louis

Emily Jackson,

AMBOSS SE

MD,

MPH,

Medical

Editor,

Laura Jacobson, PhD, MPH, Assistant Professor,

OHSU-PSU School of Public Health, Portland State

University

Ruvani Jayaweera, PhD, MPH, Senior Research

Scientist, Ibis Reproductive Health

Ashley

Jeanlus,

Parenthood

MD,

Physician,

Carole Joffe, PhD, Professor,

California, San Francisco

Planned

University

of

Nicole E. Johns, MPH, Research Data Analyst,

University of California San Diego

Dana M Johnson, MPAff, PhD, Postdoctoral

Fellow, University of Wisconsin-Madison School of

Medicine and Public Health

Heidi E. Jones, PhD, MPH, Professor, CUNY

School of Public Health

Kelly M. Jones, PhD, Associate Professor, American

University

Rachel K. Jones, PhD, Principal Research Scientist,

Guttmacher Institute

Rebecca Joseph, MD, MPH, Physician, Women’s

Health Services

Jennifer Kaiser, MD, MA, MSCI, Associate

Professor, Primary Investigator, University of Utah

15a

Shelly Kaller, MPH, Project Director, University of

California San Francisco

Helena Kopp Kallner, MD, PhD, Professor,

Karolinska Institutet

Bliss Kaneshiro, MD, MPH, Professor and Chief,

University of Hawaii

Farzana Kapadia, PhD, MPH, Professor of

Epidemiology, School of Global Public Health, New

York University

Nathalie Kapp, MD, MPH, Chief Medical Advisor,

International Planned Parenthood Federation

Jennifer Karlin, MD, PhD, Associate Professor,

University of California, San Francisco

Megan Kavanaugh, DrPH, Principal Research

Scientist, Guttmacher Institute

Brianna Keefe-Oates, PhD, MPH, Independent

Researcher

Kimberly Kelly, PhD, Professor, Mississippi State

University

Courtney Kerestes, MD, MSCTR,

Professor, University of Minnesota

Assistant

Jennifer Kerns, MD, MS, MPH,

University of California, San Francisco

Professor,

Katherine Key, MPH, Senior Associate Research

Scientist, Ibis Reproductive Health

Katrina Kimport, PhD, Professor, University of

California, San Francisco

Sarah G. Kirshner, MD, Complex Family Planning

Fellow, University of California, Davis

16a

Zoe Klett, N/A, Interim Executive

Reproductive Health Access Project

Director,

Jennifer Ko, MLIS, Project Director, University of

California, San Francisco

Leah Koenig, PhD, MSPH, WeCount Director,

Society of Family Planning

Kathryn Kost, PhD, Director of Domestic Research,

Guttmacher Institute

Bhavik Kumar, MD, MPH, Chief Medical Officer,

Planned Parenthood Greater Ohio

Miriam Kuppermann, PhD, MPH, Professor,

University of California, San Francisco

Lauren Kus, MD, Clinical Assistant Professor, NYU

Kathryn J. LaRoche, PhD,

Professor, Purdue University

MSc,

Assistant

Jackline Joy Lasola, MD, PhD, MSc, Resident

Physician and Researcher, University of California,

San Francisco

Gary Scott Leiserowitz, MD, MS, Professor and

Chair, Dept of OB/GYN, University of California,

Davis Medical Center

Klaira Lerma, MPH, Researcher, University of

Wisconsin - Madison

Amy Levi, PhD, MSN, Consultant, New Mexico

Department of Health

Amy Lewin, PsyD, Associate Professor, University

of Maryland

17a

E(dward) Steve Lichtenberg, MD, MPH,

Professor of Clinical OB-GYN, Prentice Women’s

Hospital Northwestern Chicago Illinois

Hannah Light-Olson, MD, Resident Physician,

University of California San Francisco

Laura Lindberg, PhD, Professor, Rutgers School of

Public Health

Megan Lobel, MD, Fellow, University of California,

San Francisco

April Lockley, DO, Physician, Miscarriage and

Abortion Hotline

Kelsey Loeliger, MD, PhD, Assistant Professor /

Affiliate, University of California San Diego

Patricia A. Lohr, MD, MPH, Director of Research

and Innovation, British Pregnancy Advisory Service

Dana Loll, PhD, MHS, Research Associate

Professor, CONVERGE, University of Pittsburgh

Alina Luke, PhD, MPH, Researcher, Emory

University Rollins School of Public Health; Center for

Reproductive Health Research in the Southeast

Isaac Maddow-Zimet,

Guttmacher Institute

MS,

Data

Scientist,

Tuyet Mai Ha Hoang, MS, PhD, Assistant

Professor, University of Illinois Urbana-Champaign

Meredith Manze, MPH, PhD, Associate Professor,

City University of New York

Alice Mark, MD, MSc, Medical Advisor, National

Abortion Federation

18a

Julie Maslowsky, PhD, Associate Professor of

Nursing and Public Health, University of Michigan,

Ann Arbor

Danielle

Mazza,

MD,

FRACGP,

MBBS,

DRANZCOG, Professor and Head, Department of

General Practice, Monash University

Monica Rose McLemore, PhD,

Professor, New York University

MPH,

RN,

Hayley V. McMahon, MSPH, Doctoral Fellow,

Emory University Rollins School of Public Health

Karen Meckstroth, MD, MPH,

University of California, San Francisco

Professor,

Biftu Mengesha, MD, MAS, Associate Professor,

University of California, San Francisco

Rebecca J. Mercier, MD, MPH, Clinical Assistant

Professor, Warren Alpert Medical School Brown

University

Madeline Merwin, MD, Resident, University of

California, San Francisco

Ghazaleh Moayedi, DO, MPH, FACOG, President,

Physician, Pegasus Health Justice Center

Sepideh Modrek, PhD, Professional, San Francisco

State University

Ann M. Moore, PhD, Principal Research Scientist,

Guttmacher Institute

Caroline Moreau, MD, MPH, PhD, Professor,

Bloomberg school of public health, Johns Hopkins

university

Natalie Morris, MPH, Project Manager, University

of California, San Francisco

19a

Heidi Moseson, PhD, MPH, Senior Research

Scientist, Ibis Reproductive Health

Elizabeth Mosley, PhD, MPH, Assistant Professor,

University of Pittsburgh School of Medicine

Isabel Muñoz, MPH, Researcher, University of

California, San Francisco, Advancing New Standards

in Reproductive Health

Sarah Munro, PhD, MA, BA (Hon), Assistant

Professor, University of Washington

Emma Chew Murphy, MD, Assistant Professor,

University of California, San Francisco

Caitlin Myers, PhD, John G. McCullough Professor

of Economics, Middlebury College

Subasri Narasimhan, PhD, MPH, Research

Director, UCLA Center on Reproductive Health, Law,

and Policy

Monika Nayak, PhD candidate, Researcher,

University of California, Los Angeles

Anita L. Nelson, MD, Professor OB-GYN,

Researcher, Professor and Chair of OB & GYN,

Western University of Health Sciences Professor

Emeritus, OB & GYN, David Geffen School of

Medicine at UCLA Clinical Professor OB & GYN,

University Southern California

Sara Newmann, MD, MPH, Professor, University of

California, San Francisco

Anna Newton-Levinson, PhD, MPH, Assistant

Professor, Emory University

20a

Brian T. Nguyen, MD, MSc, Associate Professor,

Los Angeles General Medical Center, University of

Southern California

Natalie Nguyen, MD, MPH, Resident, University of

California, San Francisco

Malini Nijagal, MD, MPH, Professor, University of

California, San Francisco

Alison Norris, MD, PhD, Professor and Chair, Ohio

State University

Jenny O'Donnell, DSc, MS, Vice President of

Research and Evaluation, Society of Family Planning

Natalie Ohly, MD, MSc, Assistant Professor, Mount

Sinai

Odera Okafor, MD, MPp, Resident Physician,

University of California, San Francisco

Lauren Owens, MD, MPH, Associate Professor,

University of Washington

Amy E. Paris, MD, MS, Assistant Professor of

Obstetrics and Gynecology, Geisel School of Medicine

at Dartmouth

Jasmine Patel, MD, Assistant Professor, UCI

Rachel Perry, MD, MPH, Associate Professor,

University of California, Irvine

Beth Phillips, MPH, Project Director, University of

California, San Francisco

Mayra Pineda-Torres, PhD, Assistant Professor,

Georgia Tech

Emma Pliskin, MPH, Research Scientist, Child

Trends

21a

Michael S. Policar, MD, MPH, Professor Emeritus

ObGyn and RS, University of California, San

Francisco School of Medicine

Sarah Prager, MD, MAS, Professor, University of

Washington

Kimala Price, PhD, Professor and Chair, San Diego

State University

Linda Prine, MD, Professor of Family and

Community Medicine, Mount Sinai School of

Medicine

Deirdre Quinn, PhD, MSc, MLitt, Assistant

Professor, University of Pittsburgh

Sarah Raifman, PhD, Project Director, University

of California, San Francisco

Tina Raine-Bennett, MD, MPH,

University of California, San Francisco

Professor,

Jessika Ralph, MD, MSCI, Associate Professor of

OB/GYN, University of Minnesota

Lauren Ralph, PhD, MPH, Associate Professor,

University of California, San Francisco

Stephanie Rand, MD, MAS, Director of Family

Planning, Health and Hospitals: Harlem Hospital

Moira Rashid, MD, MPH, Physician, PPLA

Elizabeth Gray Raymond, MD, MPH, Clinical

Assistant Professor, Department of Obstetrics and

Gynecology, University of Washington

Sara K. Redd, PhD, MSPH, Assistant Professor,

Emory University

22a

Hannah Reiser, MD MSc, Health

Assistant Clinical Professor, UCLA

Sciences

Mayra Repetto, MD, Resident, CA

Radhika Rible, MD, MSc, Health Sciences Clinical

Professor, UCLA

Whitney Rice, DrPH, Rollins Assistant Professor

and Director, Emory University

Taylor Riley, PhD, MPH, Postdoctoral Fellow,

University of North Carolina at Chapel Hill

Jeanette Rios, MD, OBGYN Resident, University of

California, San Francisco

Sarah Roberts, DrPH, Professor, University of

California, San Francisco

Corinne Rocca, PhD, MPH, Professor, University

of California, San Francisco

Roger Rochat, MD, Emeritus Professor, Emory

University

Kevin Roy, PhD, Professor, University of Maryland

college park

Susan E. Rubin, MD, MPH, Reproductive Health

Research Director, Institute for Family Health

Samantha Ruggiero, MA, Senior Project Manager,

Ibis Reproductive Health

Jennefer Russo, MD, MPH, Executive Director,

DuPont Clinic LA

Goleen Samari, PhD, MPH, MA, Associate

Professor, University of Southern California

Jessica N. Sanders, PhD, MSPH, Associate

Professor, University of Utah

23a

John Santelli, MD, MPH, Professor, Columbia

University

Raffaela Schiavon, MD, OB/GYN, Researcher,

Independent Consultant in Sexual and Reproductive

Health

Robyn Schickler, MD, MSc, Researcher and

Physician, Planned Parenthood of Florida

Courtney A. Schreiber, MD, MPH, Professor,

University of Pennsylvania

Hayley Schultz, MD, Physician, Kaiser Northern

California

Laura Schummers, DSc, Assistant Professor,

University of British Columbia

Hilary Schwandt, MHS,

Western Washington University

PhD,

Professor,

Eleanor Bimla Schwarz, MD, MS, Professor in

Residence, UC San Francisco

Dominika Seidman, MD, MAS, Associate

Professor, University of California, San Francisco

Leigh Senderowicz, DSc, MPH, Assistant

Professor, University of Wisconsin-Madison

Tania Basu Serna, MD, MPH,

University of California, San Francisco

Researcher,

Jane Seymour, PhD, MPH, Research Scientist,

University of Wisconsin-Madison

Marit Pearlman Shapiro, MD, MPH, Assistant

Professor, University of Southern California

Wendy R. Sheldon, PhD, MPH, MSW, Founder,

Researcher, Verge Research

24a

Renee Bracey Sherman, MPA, Scholar, American

University

Tara Shochet, PhD, MPH

Gretchen Sisson, PhD, Sociologist, Advancing New

Standards in Reproductive Health, University of

California, San Francisco

Mikaela Smith, PhD, Research Scientist, The Ohio

State University

Mindy Sobota, MD, MS, MPhil, FACP, Associate

Professor of Medicine, Alpert Medical School of Brown

University

Ellen Solis, DNP, CNM, Associate Professor,

University of Washington

Reni Soon, MD, MPH, Professor, University of

Hawaii John Burns School of Medicine

Silpa Srinivasulu, MPH, PhDc, Researcher, CUNY

Graduate School of Public Health & Health Policy

Jody Steinauer, MD, PhD, Professor, University of

California, San Francisco

Julia Steinberg, PhD, Associate Professor,

Department of Family Science, School of Public

Health, University of Maryland, College Park

Amanda Stevenson, PhD, Associate Professor,

University of Colorado Boulder

Rachel Steward, MD, MSc, Medical director, FPA

Women’s Health

Julia Strasser, DrPH, MPH, Assistant Research

Professor, George Washington University

25a

Debra Stulberg, MD, Professor, University of

Chicago

Daniel Felipe Martín Suárez-Baquero, PhD,

MSN, BSN-RN, Assistant Professor, University of

Washington, School of Nursing

Siri Suh, PhD, MPH, Associate Professor, Brandeis

University

Elisabeth Sulger, MD, Complex Family Planning

Fellow, University of Rochester

Elizabeth Sully, PhD, Director of International

Research, Guttmacher Institute

Laura Swan, PhD, LCSW, Senior Research

Scientist, Reproductive Equity Action Lab, University

of Wisconsin School of Medicine and Public Health

Jonas Swartz, MD, MPH, Associate Professor, Duke

University Health System

Kai Tao, ND, MPH, CNM, Principal, ICAN

Jessica Tarleton, MD, MPH, Assistant Professor,

University of Maryland School of Medicine

Julia Tasset, MD, MPH, Assistant Professor,

Oregon Health & Science University

Paula Tavrow, PhD, Adjunct Professor, UCLA

Fielding School of Public Health

DeShawn Taylor, MD, MSc, Associate Clinical

Professor of Obstetrics and Gynecology, University of

Arizona College of Medicine Phoenix

Stephanie B. Teal, MD, MPH, Professor and Chair,

Case Western Reserve University School of Medicine

26a

Terri-Ann Thompson, PhD, Senior Research

Scientist, Ibis Reproductive Health

Angeline Ti, MD, MPH, Faculty, Wellstar Heath

System

Leah Torres, MD, MS, Medical Director, Clinics for

Abortion and Reproductive Excellence

Janet M. Turan, PhD, MPH, Professor Emerita,

University of Alabama at Birmingham

David Turok, MD, MPH, Professor, University of

Utah

Erinma Ukoha, MD, MPH, Assistant Professor,

Icahn School of Medicine at Mount Sinai

Ushma Upadhyay, PhD, MPH,

University of California, San Francisco

Professor,

Josephine Urbina, MD, Assistant

University of California, San Francisco

Professor,

Jessica Valdez, MD, MPH, Resident, University of

California, San Francisco

Alicia VandeVusse, PhD, Principal Research

Scientist, Guttmacher Institute

Marissa Velarde, PhD, MPH, Postdoctoral

Research Fellow, San Diego State University

Suzanne Veldhuis, MD, MSc, PhD, Postdoctoral

Researcher, El Colegio de la Frontera Sur

Robin Wallace, MD, MAS, Physician, Planned

Parenthood South Atlantic

Lin-Fan Wang, MD, MPH, Assistant Progressor,

Thomas Jefferson University Hospitals

27a

Ortal Wasser, PhD, MSW, Adjunct faculty, New

York University

Carol S. Weisman, PhD, Distinguished Professor

Emerita of Public Health Scienced, Pennsylvania

State University College of Medicine

Tracy A Weitz, PhD, MPA, Professor, American

University

Elisa S. Wells, MPH, Co-Founder, Access Director,

Plan C

Carolyn Westhoff,

Columbia University

MD,

Professor

Emerita,

Sara Whetstone, MD, MHS, Professor, University of

California, San Francisco

Ariel White, MD, Associate Medical Director,

Attending - Adolescent and Young Adult Medicine,

American University, Children’s National Medical

Center

Kari White, PhD, MPH, Executive and Scientific

Director, Resound Research for Reproductive Health,

a project of the Tides Center

Brooke Whitfield, PhD, Postdoctoral Research

Associate, University of Wisconsin-Madison

Tracey Wilkinson, MD, MPH, Associate Professor

of Pediatrics and Obstetrics & Gynecology, Indiana

University

Caitlin Williams, PhD, MSPH, Principal, Mirae

Insights

Erin Wingo, MSPH, Project Director, University of

California, San Francisco

28a

Beverly Winikoff, MD, MPH, President of Gynuity

Health Projects

Elizabeth Witwer, MPH, Senior Manager of

Research Development & Engagement, New York

University

Diana Wohler, MD, Assistant Professor, Warren

Alpert Medical School at Brown University

Alexandra Wollum, PhD, MPH,

Scientist, Ibis Reproductive Health

Research

Melissa L. Wong, MD, Assistant Professor,

Montefiore Medical Center / Albert Einstein College

of Medicine

Katie Woodruff, DrPH, Researcher, University of

California, San Francisco

Liana Woskie, PhD, MSc, Assistant Professor,

Tufts University

Tricia Wright, MD, MCR, Professor, University of

California, San Francisco

Sarah Wulf, MPH, Project Director, University of

California, San Francisco

Alicia Ely Yamin, JD, MPH, PhD, Lecturer on Law,

Senior Adjunct Lecturer on Health Policy and

Management, Harvard University

Enav Zusman, PharmD, MSc, Researcher,

Pharmacist, The University of British Columbia

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.